The regulatory landscape for ship recycling

In view of increased concern about various environmental issues, the focus on the use of non-hazardous materials in ship design, building and operation is also increasing. Two regulations, presently governing the requirements of the Inventory of Hazardous Materials (IHM) and authorization of ship recycling facilities, are:

  • The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), in force for European flagged vessels and 3rd party flagged vessels, visiting European ports or anchorages, equal to and above 500 GT.
  • Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in June 2025.

The Inventory of Hazardous Materials (IHM) in a nutshell

The IHM is a list of hazardous materials that are present on a ship. The IHM quantifies and locates hazardous materials on board ships which are known to represent a potential hazard to people and the environment. 

The IHM consists of three parts:

  • Part I: Hazardous materials contained in the ship’s structure and equipment (Refer to “IHM Part I Certification” page for details)
  • Part II: Operationally generated wastes
  • Part III: Stores

The IHM Part I is prepared either during the construction of the ship or while the vessel is in operation. For latter, hazmat experts should be contracted for the preparation of the IHM. Refer to the list of approved service suppliers for IHM preparation. Search | Approval finder (dnv.com) 

IHM Part II and III shall be prepared by the shipowner once the decision is given to send the ship for recycling. The IHM Part II and III can be prepared by the crew or by a hazmat expert. (Refer to “Ready for Recycling Certificate” page for details)

IHM and Ship Recycling (body image)

Scope of the IHM

Maintain the IHM to stay compliant

Once the IHM Part I is certified, it must be kept up to date and maintained throughout the operational life of the vessel. IHM Maintenance can either be done by the shipowner/shipmanager itself as inhouse or outsourced to 3rd party hazmat experts.

The details on IHM Maintenance is described in “IHM Part I Maintenance” page.

DNV offers services for

  • IHM Part I approval and certification
  • IHM Manager software for IHM Maintenance
  • IHM Part II & III approval and Ready for Recycling certification

MD Form

Download MD template suitable for EU Regulation and IMO MEPC.269 (68)

More on ship recycling, IHM, HazMat: